Personal Injury Complaint - Slip and Fall

SUPERIOR COURT OF THE STATE OF CONNECTICUT

Judicial District of [PLACEHOLDER – JUDICIAL DISTRICT]
Docket No.: [___]

[PLAINTIFF FULL LEGAL NAME],
  Plaintiff,

v.

[DEFENDANT FULL LEGAL NAME],
  Defendant.

COMPLAINT – PREMISES LIABILITY (SLIP-AND-FALL)

Date: [___]

TABLE OF CONTENTS

1. Parties
2. Jurisdiction and Venue
3. Factual Allegations
4. Count One – Negligence (Premises Liability)
5. Damages
6. Prayer for Relief
7. Demand for Jury Trial (Optional)
8. Statement of Amount in Demand
9. Certification of Service

1. PARTIES

1.01 Plaintiff, [PLAINTIFF NAME] (“Plaintiff”), is an individual resident of the State of ☐ and, at all relevant times, was lawfully present on the premises described herein.

1.02 Defendant, [DEFENDANT NAME] (“Defendant”), is a [corporation/LLC/partnership/individual] organized and existing under the laws of the State of ☐ with its principal place of business at [ADDRESS]. Defendant owned, possessed, controlled, and/or maintained the premises located at [PREMISES ADDRESS] (the “Premises”) at all relevant times.

2. JURISDICTION AND VENUE

2.01 Jurisdiction is proper in this Court pursuant to Conn. Gen. Stat. § 51-164s and P.B. § 10-21 because the damages claimed exceed the statutory minimum for monetary relief, exclusive of interest and costs.

2.02 Venue is proper in the Judicial District of [JURISDICTION] pursuant to Conn. Gen. Stat. § 51-345 because the cause of action arose in this district and/or the Defendant transacts business and may be found here.

3. FACTUAL ALLEGATIONS

3.01 On [DATE] at approximately [TIME], Plaintiff was an invitee/business patron lawfully on the Premises.

3.02 While traversing [describe specific location, e.g., “the tiled foyer adjacent to the main entrance”], Plaintiff slipped and fell due to [describe hazard—e.g., “an accumulation of water and cleaning solution with no warning signs”] (the “Hazardous Condition”).

3.03 At all relevant times, Defendant, by and through its agents, servants, and/or employees, knew or, in the exercise of reasonable care, should have known of the Hazardous Condition.

3.04 Defendant failed to:

a. Inspect and maintain the Premises in a reasonably safe condition;
 b. Warn Plaintiff of the Hazardous Condition;
 c. Remedy or cordon off the Hazardous Condition within a reasonable time; and
 d. Adopt reasonable safety and cleaning protocols to prevent such hazards.

3.05 As a direct and proximate result of Defendant’s negligence, Plaintiff suffered serious personal injuries and related damages more fully set forth below.

4. COUNT ONE – NEGLIGENCE (PREMISES LIABILITY)

4.01 Plaintiff repeats and realleges ¶¶ 1.01–3.05 as if fully set forth herein.

4.02 Defendant owed Plaintiff a non-delegable duty to maintain the Premises in a reasonably safe condition and to protect against foreseeable hazards.

4.03 Defendant breached said duty by the acts and omissions described in ¶ 3.04.

4.04 Defendant’s breach was the direct and proximate cause of Plaintiff’s injuries and losses.

4.05 Plaintiff’s injuries include, but are not limited to:
 a. [Physical injuries – e.g., “left ankle fracture requiring open reduction and internal fixation”];
 b. Pain and suffering, both past and future;
 c. Lost wages and diminution of earning capacity;
 d. Past and future medical expenses;
 e. Loss of enjoyment of life; and
 f. Any and all other damages proven at trial.

5. DAMAGES

5.01 Pursuant to P.B. § 10-21, Plaintiff seeks monetary damages in excess of Fifteen Thousand Dollars ($15,000.00), exclusive of interest and costs.

5.02 Plaintiff reserves the right to amend this Complaint to claim additional special damages as they become known.

6. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in Plaintiff’s favor and against Defendant as follows:

A. Compensatory damages in an amount to be determined by the trier of fact;
B. Pre-judgment and post-judgment interest as allowed by law;
C. Costs of suit under Conn. Gen. Stat. § 52-257;
D. Such other and further relief as the Court deems just and proper.

7. DEMAND FOR JURY TRIAL [OPTIONAL]

Pursuant to Conn. Gen. Stat. § 52-215 and P.B. § 16-1, Plaintiff demands a trial by jury on all issues so triable.

8. STATEMENT OF AMOUNT IN DEMAND

In accordance with Conn. Gen. Stat. § 52-91 and P.B. § 8-2, the amount, legal interest and property in demand is greater than Fifteen Thousand Dollars ($15,000.00), exclusive of interest and costs.

9. CERTIFICATION OF SERVICE

I hereby certify that a copy of the foregoing Complaint was or will be mailed or delivered electronically or non-electronically on [DATE OF SERVICE] to all counsel and pro se parties of record in accordance with P.B. §§ 10-12 and 10-13.

Respectfully submitted,

______________________________
Signature
[ATTORNEY NAME], Esq.
Juris No.: [___]
[LAW FIRM NAME]
[ADDRESS]
Tel: [___]
E-mail: [___]
Attorney for Plaintiff

VERIFICATION (If Required)

I, [PLAINTIFF NAME], being duly sworn, state that I have read the foregoing Complaint and that the allegations therein are true to the best of my knowledge and belief.

______________________________
[PLAINTIFF NAME]

Subscribed and sworn to before me on this ___ day of ________, 20__.

______________________________
Notary Public / Commissioner of the Superior Court
My Commission Expires: [___]